In weighing the preponderance of the evidence, the trial court's findings of fact that are based on witness credibility are given great weight, and they will not be overturned absent clear and convincing evidence to the contrary. In re Adoption of A.M.H. , 215 S.W.3d 793, 809 (Tenn. 2007) ; see alsoReeder v. Reeder , 375 S.W.3d 268, 278–79 (Tenn. Ct. App. 2012) (citing Adelsperger v. Adelsperger , 970 S.W.2d 482, 485 (Tenn. Ct. App. 1997) ) ("Decisions concerning custody and visitation often hinge on subtle factors, such as the parents' demeanor and credibility during the proceedings."). We first address Mother's argument that the trial court erred in naming Father the primary residential parent.
The "process and criteria for ascertaining a parent's child support obligation is governed by Child Support Guidelines promulgated by the Tennessee Department of Human Services[.]" Beyer v. Beyer, 428 S.W.3d 59, 73 (Tenn. Ct. App. 2013) (quoting Reeder v. Reeder, 375 S.W.3d 268, 275 (Tenn. Ct. App. 2012)).
In Tennessee, prejudgment interest on unpaid child support is governed by Tennessee Code Annotated § 36-5-101. See Reeder v Reeder, 375 SW.3d 268, 281 (Tenn Ct. App. 2012). Postjudgment interest is governed by Tennessee Code Annotated § 47-14-122.
Id.Reeder v. Reeder, 375 S.W.3d 268, 278 (Tenn. Ct. App. 2012). This Court explained in a previous case that a court order including "a lengthy summary of the testimony adduced at the hearing and a few credibility observations" without further indicating which testimony or other evidence the trial court relied upon in making its decision is not sufficient to satisfy the requirement of making specific findings of fact.
The criteria for ascertaining a parent's child support obligation is governed by Child Support Guidelines promulgated by the Tennessee Department of Human Services, in accordance with Tennessee Code Annotated section 36-5-101(e). The law set out in Reeder v. Reeder, 375 S.W.3d 268, 275-76 (Tenn. Ct. App. 2012) is applicable here. The amount of support derived from a proper application of the formula in the Child Support Guidelines becomes the presumptive child support.
"Trial courts have broad discretion to fashion custody and visitation arrangements that best suit the unique circumstances of each case, and the appellate courts are reluctant to second-guess a trial court's determination regarding custody and visitation." Reeder v. Reeder, 375 S.W.3d 268, 278 (Tenn. Ct. App. 2012) (citing Parker v. Parker, 986 S.W.2d 557, 563 (Tenn. 1999)); see also C.W.H. v. L.A.S., 538 S.W.3d 488, 495 (Tenn. 2017) (quoting Armbrister v. Armbrister, 414 S.W.3d 685, 693 (Tenn.
We note, however, that "[t]rial courts have broad discretion to fashion custody and visitation arrangements that best suit the unique circumstances of each case, and the appellate courts are reluctant to second-guess a trial court's determination regarding custody and visitation." Reeder v. Reeder, 375 S.W.3d 268, 278 (Tenn. Ct. App. 2012) (citing Parker v. Parker, 986 S.W.2d 557, 563 (Tenn. 1999)); see also C.W.H. v. L.A.S., 538 S.W.3d 488, 495 (Tenn. 2017) (quoting Armbrister v. Armbrister, 414 S.W.3d 685, 693 (Tenn.
The formula found in the Child Support Guidelines sets the presumptive amount of support, but a trial court has discretion to deviate from the presumptive amount in certain instances. Reeder v. Reeder, 375 S.W.3d 268, 275 (Tenn. Ct. App. 2012) (citing Ballard v. Herzke, 924 S.W.2d 652, 661 (Tenn. 1996)).
Child support obligations are determined according to the Tennessee Child Support Guidelines, but trial courts have discretion to grant credits or otherwise deviate from presumptive child support obligations. Reeder v. Reeder, 375 S.W.3d 268, 275 (Tenn. Ct. App. 2012) (citing Ballard v. Herzke, 924 S.W.2d 652, 661 (Tenn. 1996)).
(quoting Reeder v. Reeder, 375 S.W.3d 268, 278 (Tenn. Ct. App. 2012)). The determination by the court of custody and visitation